Berta Jackson owns 100% of the common stock of Almond Corporation

(E & P of $1.5 million), having purchased the stock 15 years ago. Berta is contemplating a gift of 45% of her shares in Almond (basis of $100,000, fair market value of $1 million) to a qualified charitable organization. Under Berta’s plan, Almond would then redeem the charitable organization’s shares in the corporation, and the charity would use the redemption proceeds to finance the construction of a soccer complex in a low-income neighborhood.

Berta’s objectives are to claim a charitable contribution deduction of $1 million for the gift of the Almond shares and retain sole ownership in Almond after the corporation’s redemption of stock from the charitable organization. However, a CPA friend of Berta’s has warned her to be careful to avoid the assignment of income doctrine. Uncertain as to the meaning of her friend’s warning, Berta has asked you for advice as to how to proceed with her plan. What advice would you give Berta so that she can achieve her objectives?